The French Anti-Corruption Agency’s (AFA) First Sanctions Decision: A Warning for Companies Subject to the Sapin II Law

Muriel Goldberg-Darmon, Guillaume Guérin, and Pierre Wolman examine the French Anti-Corruption Agency’s (AFA) first monetary sanction for violations of the Sapin II anti-corruption compliance requirements in an article published by Finascope. The article discusses the key lessons from the landmark decision and its implications for companies subject to Sapin II, including the importance of maintaining effective anti-corruption compliance programs that are fully operational before any inspection by the AFA.